An SPCC Plan should reflect the way a facility currently stores, handles, and transfers oil. Over time, tanks may be added, equipment may deteriorate, and operating procedures may change.
SPCC stands for Spill Prevention, Control, and Countermeasure. The federal rule is intended to prevent oil from reaching navigable waters or adjoining shorelines. It may apply to facilities with more than 1,320 gallons of aboveground oil storage capacity or more than 42,000 gallons of completely buried storage capacity when there is a reasonable possibility of a discharge reaching nearby waters. Containers with a capacity below 55 gallons are generally not counted toward the aboveground threshold.
An SPCC Plan should reflect the way a facility currently stores, handles, and transfers oil. Over time, tanks may be added, equipment may deteriorate, and operating procedures may change. An up-to-date SPCC Plan helps ensure a facility has effective measures in place to prevent oil spills and is prepared to respond quickly and effectively if one occurs.
The EPA provides more information about determining whether the SPCC rule applies to a facility.
What Is an SPCC Inspection?
An SPCC inspection reviews the equipment, procedures, and site conditions included in a facility’s SPCC Plan. Routine inspections help facilities identify issues before they contribute to a spill or create a larger compliance concern.
The inspection may include oil storage containers, piping, transfer areas, secondary containment, drainage controls, spill response materials, and facility records.
There is no single inspection schedule that applies to every facility. The frequency and scope should follow the written procedures in the SPCC Plan, accepted engineering practices, and applicable industry standards.
The following checklist provides a practical starting point. Each facility should still follow the procedures established in its own Plan.
1. Confirm the SPCC Plan Matches Current Operations
Start by comparing the written Plan with current facility conditions.
Review the facility diagram, oil storage inventory, inspection procedures, and previous inspection records. Confirm that fixed tanks, portable storage areas, transfer locations, and connecting piping are represented accurately.
Look for changes that may have occurred since the Plan was prepared. These may include new tanks, relocated containers, different oil products, facility expansions, or changes to drainage and containment systems.
An outdated Plan can leave important equipment or potential spill pathways unaddressed. Changes that materially affect the facility’s discharge potential may also require the Plan to be amended and re-certified by a licensed Professional Engineer.
2. Inspect Tanks and Oil Storage Containers
Check applicable tanks, drums, totes, and portable containers for visible signs of deterioration, staining, or active leaks.
Tank corrosion, dents, bulging, damaged seams, or loose fittings could all be potential release points. Valves, vents, gauges, fill connections, foundations, and supports should also be reviewed for damage.
Inspect the area around each container. Staining on the ground, residue beneath a valve, or damaged vegetation may indicate a small or recurring release.
Portable containers should be stored in the locations identified by the SPCC Plan. They should also be protected from vehicle traffic and other conditions that could damage them.
Visual inspections do not always replace formal integrity testing. The appropriate testing method and schedule depend on the container, its condition, and the procedures established in the Plan.
3. Review Secondary Containment and Drainage
Secondary containment is intended to keep discharged oil from leaving the storage or transfer area.
Inspect berms, dikes, curbs, liners, walls, sumps, and catchment areas. Look for cracks, holes, erosion, damaged coatings, standing oil, or debris that could reduce containment capacity.
For many bulk storage installations, containment must hold the capacity of the largest single container while allowing additional room for precipitation. It must also be capable of containing oil until cleanup can occur.
Accumulated precipitation inside secondary containment can reduce the available containment capacity, and therefore should be removed. Drain valves should be positioned according to the SPCC Plan. Before rainwater is released from a diked area, it should be inspected for visible oil or other signs of contamination. The SPCC Plan provides facility-specific procedures to follow for discharging precipitation from containment.
The inspection should also consider nearby storm drains, ditches, culverts, slopes, and low points. Construction, erosion, or changes in site grading can create new spill pathways.
4. Inspect Piping and Transfer Areas
Piping and transfer equipment can develop leaks because of movement, corrosion, impact, or routine wear.
Inspect hoses, pumps, valves, flanges, joints, connections, pipe supports, and exposed metal surfaces. Look for worn seals, loose connections, damaged coatings, oil in drip pans, or staining beneath equipment.
Loading and unloading areas deserve close attention because they experience frequent equipment use and vehicle activity.
Confirm that overfill prevention equipment is functioning as intended. This may include gauges, alarms, shutoff systems, or communication procedures between employees.
Employees responsible for transfers should understand who is monitoring the process and what steps to take if a leak or overfill occurs.
5. Check Spill Response Equipment
Spill response materials should be available, accessible, and appropriate for the potential spills identified in the Plan.
Depending on the facility, supplies may include absorbent pads, booms, drain covers, recovery containers, protective equipment, and cleanup tools.
Check that materials have not expired, deteriorated, or been used without replacement. Employees should know where the equipment is stored and how to use it.
Emergency contact information should also be reviewed. Confirm that names and phone numbers are current for facility personnel, cleanup contractors, and applicable government agencies.
A response procedure will not work well if the necessary equipment is missing or the listed contact no longer works at the facility.
6. Review Training and Inspection Records
Employees who handle oil should understand the facility’s spill prevention procedures and know how to respond to a discharge.
Review training records for current personnel. Confirm that new employees received appropriate instruction and that required routine spill prevention briefings have been completed.
Inspection records should clearly identify the date, area inspected, equipment reviewed, findings, corrective actions, and inspector.
Avoid vague notes such as “needs attention.” The record should explain what was observed, what action is required, who is responsible, and when the work should be completed.
Required inspection and testing records must be signed by the appropriate supervisor or inspector and kept with the SPCC Plan for at least three years.
7. Complete Corrective Actions
The inspection is not finished when the form is signed.
Each deficiency should be assigned to a responsible person. The record should include the required corrective action, a completion date, and a method for confirming that the work was completed.
Conditions that present an immediate spill risk should be addressed promptly. Repeated findings may point to a larger maintenance, training, or management issue.
Inspection results may also show that the SPCC Plan no longer reflects current operations. Owners and operators should review the Plan after relevant facility changes and complete the required five year evaluation.
Common SPCC Inspection Mistakes
One common mistake is using a generic checklist that does not match the equipment and procedures described in the facility’s SPCC Plan.
Other common issues include outdated container inventories, missing signatures, incomplete corrective actions, outdated facility diagrams, missing drainage records, and spill supplies that have not been replaced.
Facilities should also avoid treating inspections as a paperwork exercise. The purpose is to identify conditions that could cause a discharge and correct them before a larger problem develops.
Support for SPCC Inspections and Plan Updates
A strong SPCC inspection program should reflect the facility’s current equipment, operating conditions, and spill risks. It should also produce clear records and lead to timely corrective action.
Ensolum’s Engineering and Compliance services include SPCC Plan development, compliance evaluations, inspections, and Plan reviews and updates.
Ensolum manages field-wide SPCC portfolios for several clients, including a field wide SPCC Plan review involving more than 500 oil and gas production facilities, disposal facilities, compressor stations, and gas plants across Colorado and Wyoming.
Contact Ensolum to discuss an SPCC inspection, Plan review, or compliance evaluation for your facility.
This article provides general information and is not a substitute for a facility specific regulatory evaluation or professional advice.